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Non Compete Agreements
Can I Void a Non-Compete Agreement in New York?
Jan 5, 2022 | By Ottinger Employment Lawyers | Read Time: 3 minutes
A non-compete agreement might seem like a trivial work request when you sign it, but the terms of that agreement can severely limit your ability to make a living after you separate from your employment. So what happens if you signed a non-compete agreement that has eliminated your job prospects? There are ways around a non-compete agreement, but you need to know what to look for in the agreement terms and characteristics of your old job. How Does a Non-Compete Work? A business might maintain a competitive edge by offering a superior product, offering better prices, keeping business and product formulas a secret, or preventing its employees from working for a competitor. Non-compete agreements keep former employees from directly competing with a business by barring them from doing certain work for competing businesses or in certain geographical areas. When you apply for a new job, your prospective employer might ask you if you're subject to any non-compete agreements. If a prospective employer believes that non-compete terms make hiring you too risky, you could lose a job opportunity. Also, a former employer could sue you for breaking a non-compete agreement. If you lose at trial, you might lose your new job and have to pay damages. Breaking a non-compete agreement can be painful, so it's important to know your options for voiding a non-compete contract before you sign one and before you apply for a new job. How Do I Get Out of a Non-Compete Agreement? The first step to voiding a non-compete contract is understanding when a non-compete agreement is enforceable in New York. To help prevent employee abuse, the State of New York requires that non-compete contracts adhere to the following guidelines: Their terms must be necessary to protect the employer's legitimate interests, Their terms can't impose an undue hardship on the employee, Their terms can't harm the public, and The time period and geographic scope they cover must be reasonable. If a non-compete agreement doesn't comply with these guidelines, it's unenforceable as written. A court might rewrite an unenforceable agreement or throw the whole agreement out altogether. You Can Void a Non-Compete by Proving Its Terms Aren't Necessary Many employers use non-compete agreements to prevent skilled employees with company secrets from taking their skills and secrets to competitors. If your work with your former employer didn't require specialized skills or didn't give you access to confidential business information, a court might deem the contract terms unnecessary and free you from restrictions on your job search. If you want to void a non-compete agreement, you should be clear about your former job obligations and the tools you needed to fulfill them. You Can Void a Non-Compete by Proving How Severely Its Terms Would Affect You The inability to make a living could be an "undue hardship" that renders a non-compete unenforceable. Think about your job skills and the specific terms of the non-compete agreement you signed. If the terms of the agreement make it almost impossible for someone with your skills to find a new job, you might be able to void the agreement. But be aware that the inability to make the same wages or work the same exact job isn't always an undue hardship. You Can Void a Non-Compete by Proving Your Job Skills Are Rare and Necessary for Public Health If the job you perform helps the public in a significant way (e.g., healthcare, environmental protection, etc.) and there aren't many people in your area who can do your job, non-compete agreement terms that prevent you from working might create unenforceable harm to the public. You Can Void a Non-Compete by Proving Its Terms Go Too Far or Last Too Long Whether a non-compete is unenforceable because it covers too large of a geographical area or it lasts too long can depend on many factors. Enforceability can depend on your industry, skills, location, etc. An experienced employment attorney can determine what non-compete terms aren't reasonable in your case. Seek Attorney Help to Fight for Your Livelihood At Ottinger Employment Lawyers, we are consistently successful and aggressive advocates for employees' rights. We have also experienced attorneys who value constant communication with our clients to help ensure we get what they need. We want to help you thrive in the workplace. Give us a call at 866-234-3862 or contact us online. For details about our New York office, click here.
Can a Doctor Be Held to a Non-Compete in New York?
Aug 13, 2021 | By Ottinger Employment Lawyers | Read Time: 3 minutes
A non-compete agreement is a written contract that prohibits an employee from operating a competing business or working for a competitor in a specified geographic area for a specified period of time. A non-compete agreement may be a separate agreement, or clause in an overarching employment contract. What Does a Physician Non-Compete Agreement Do? Most physicians are familiar with non-compete agreements. Some courts refer to these as restrictive covenants not to compete. Medical employers frequently use these instruments to protect their medical practice from competition by former physician employees. A physician non-compete clause especially comes into play where an employer has invested significant time and resources to provide specialized training to a physician. It would be unfair for a physician employee to simply quit after this type of valuable training, set up a practice across the street, and poach patients from their former employer. How Are Non-Compete Agreements Enforced? There are no federal laws governing the use of physician non-compete clauses. Rather, state contract law determines whether a non-compete agreement is enforceable. In New York, former employers enforce non-compete agreements. Enforcement comes in the form of a lawsuit. The former employer can ask the judge to enforce the non-compete agreement and require the former employee to abide by its terms and conditions. Although general principles of contract law apply, additional issues arise when considering non-compete agreements and particularly physician non-compete clauses. Contact Us Schedule your free consultation. When Is a Non-Compete Agreement Enforceable? To determine if a non-compete agreement is valid and enforceable, New York courts will take into consideration the language of the written contract and the former employee's job duties. New York Courts will only enforce a non-compete agreement if it satisfies the three factors we will discuss below. The Non-Compete Agreement Is Necessary to Protect the Employer's Legitimate Business Interests New York courts have recognized a broad range of legitimate employer interests safeguarded by valid non-compete agreements. These include: An employer's trade secrets or confidential information; An employer's goodwill and reputation within its industry or market; and An employer's interest in preventing competition with the former employee when the services at issue are highly specialized or unique in some way. These legitimate business interests are typically protected by the courts. The Non-Compete Agreement Does Not Impose an Undue Hardship on the Employee and Is Not Harmful to the Public Courts will strike a non-compete agreement down if it imposes an "undue hardship" on the employee, or causes "injury" to the public. For example, New York courts have held that firing an employee without cause may void an otherwise valid non-compete agreement. In another case, a court held that a non-compete agreement was void because it unduly restricted the employee's right to apply skills and knowledge acquired by the overall experience of their previous employment. The Non-Compete Agreement Is Reasonable in Time Period and Geographical Scope New York courts focus on the particular facts and circumstances of each case. Judges review a contract to determine whether the non-compete agreement is overly broad. Courts consider a clause to be overbroad if it includes an unnecessarily large geographical area or too extensive a time period. New York courts generally consider periods of six months or less to be reasonable and permissible. Some courts have even upheld non-compete agreements that extend up to two years in duration, depending on the circumstances of the case. With respect to geographical scope, state courts look to whether the prohibited area is reasonably related to the geography of the employer's medical practice. Arguments Against Non-Compete Agreements for Medical Professionals Non-compete agreements are alive and well in New York. As long as they satisfy the criteria discussed above, courts will generally enforce their terms. However, the law may be shifting somewhat. For instance, courts may scrutinize non-compete agreements that materially limit a patient's access to care or their choice of doctor. The American Medical Association (AMA) is on record stating that it, "discourages any agreement between physicians which restricts the right of a physician to practice medicine for a specified period of time or in a specified area upon termination of employment." The AMA's reasoning stems from concern for public welfare. It has stated accordingly, "[C]ovenants not to compete restrict competition, disrupt continuity of care, and potentially deprive the public of medical services." A Seasoned Employment Law Firm Who Will Fight For You For nearly 22 years, Ottinger Employment lawyers have assisted clients with many types of work-related matters. We are experienced in litigating the interests of physicians and employers alike. Whether we are fighting an unconscionable restriction on a physician's right to practice or defending an employer's right to impose reasonable restrictions on former employees, Ottinger Employment Lawyers know how to fight to obtain the results you deserve. Contact us today for a free consultation. For details about our New York office, click here.
Non-Compete Agreements in New York Overview
Jul 20, 2020 | By Ottinger Employment Lawyers | Read Time: 10 minutes
Ottinger Employment Lawyers Can Help with Non-Compete Agreements New York non-compete agreements are widely misunderstood and many of them are unenforceable. This is because New York strongly disfavors non-compete agreements and courts will not enforce them unless a company can overcome a presumption of unenforceability. New York non-competition law attempts to strike a balance to protect an employer's legitimate business interests, an employee's ability to earn a living, and the public interest in free trade. Ottinger Employment Lawyers have been assisting executives with non-compete issues since 1999. Submit the short form below to get started with a consultation. Our attorney, Robert Ottinger is an expert when it comes to non-compete agreements in New York. Watch the short video below to find out if your non-compete is enforceable. If you would like to get in contact with a New York employment law attorney, contact us today. Important Information About Non-Compete Agreements in New York Speak with an Employment Attorney About Your Non-Compete Agreement If you are looking for immediate help with a non-compete issue complete the short form below to get your free consultation started. We review your non-compete agreement and then meet with you over the phone. We will assess the agreement's enforceability and suggest strategies. Call 347-492-1904 to speak with Robert Ottinger if you have questions regarding your non-compete agreement in New York. Locked into a Non-Compete in New York? Here are five ways you can potentially defeat your New York non-compete agreement: Are you bound by a New York non-compete agreement? Are you trying to move from one employer to another in the same industry? A non-compete agreement can ruin your plans. The Ultimate Guide for Executives This article provides a brief overview of tactics that can beat a non-compete agreement. If a non-compete agreement is causing problems for you, it may be possible to invalidate it or reduce its impact. We offer a non compete review & consultation to help you understand your options. First, a little background on New York non-compete agreements. These agreements were once limited to high-level company executives who had access to company trade secrets or who developed unique skills while employed by the company. Over the past decade, however, companies have started asking rank and file employees to sign non-compete agreements. As a result, employees at all levels find themselves constrained by these agreements. It's estimated that one in five people today are bound by a non-compete clause. The overuse and abuse of non-compete agreements are also creating a backlash against them. Last year, New York Attorney General Eric Schneiderman prosecuted three companies for abusing non-compete agreements. According to the Attorney General, "unless an individual has highly unique skills or access to trade secrets, non-compete clauses have no place in a worker's employment contract." The tide has turned against non-compete agreements in New York. Courts are now more likely than ever to void these agreements. What is a Non-Compete Agreement? A non-compete agreement is a clause typically inserted into an employment or separation agreement that prohibits a person from working for a competitor of their employer for a period of time. A non-compete agreement can limit your ability to move around in your industry. By signing one, you effectively agree that if you stop working for your employer, you will leave your industry and abandon your skills and experience for a period of time that typically ranges from six months to two years. Here is a typical non-compete agreement: "Employee shall not, whether directly or indirectly, alone or as a partner, joint venturer, officer, director, employee, consultant, agent, independent contractor or stockholder of any company or business anywhere in the United States, except on behalf of the Company or with the company's written consent: Engage in the business of the company or in any business that is in competition with the business of the company, Be employed by, consult for, or provide any serviced to any person or entity that is engaged in the business of the company or is engaged in any business that is in competition with the business of the company, Solicit or accept the same or substantially related business of any other customer or account of the company or induce any customer or account of the company to cease doing business with the company or in any manner interfere with the goodwill and customer relationship of the company. The Legal Standard Used to Evaluate New York Non-Compete Agreements In New York, courts disfavor non-compete agreements and enforce them only when necessary. Here are the main factors courts consider: non competes are enforced only when necessary to protect legitimate business interests such as trade secrets or special skills acquired during employment non compete agreements must be reasonable in time and geographic reach the agreement cannot be harmful to the general public the agreement must not be unreasonably burdensome on the employee. Courts apply the same standard to non-solicitation agreements. Eight Ways to Defeat a New York Non-Compete Fired Without Cause If your employer is not willing to employ you, courts generally will not enforce a non-compete agreement. This is almost black letter law in New York, so if you were fired without cause, your non-compete agreement is not enforceable. But there is no reason to feel trapped by that non-compete agreement. It's not enforceable in this situation. A Common Scenario: Today, most New York executives are bound by non-compete agreements. And many find themselves fired without cause or laid off at some point. They feel trapped by their non-compete agreement. They want to stay in their field because that is where they offer the most value. They have bills to pay and families to support. But, their non-compete agreement forbids working in their field. I n addition, most of these executives don't have access to their former employer's trade secrets. They usually hold positions in sales, management, operations or other areas that did not necessitate access to genuine company trade secrets. If you find yourself […]
Defeating a Non-Compete Agreement
Jun 9, 2020 | By Ottinger Employment Lawyers | Read Time: 2 minutes
In this post, I'm going to show you EXACTLY how to get out of a New York non-compete agreement. In fact, this is the exact process we use to help all of our clients get out of non-compete agreements. If you want to get out of a New York non-compete agreement, you'll like this post. The graphic above makes it easy to see how this works. You can also visit FindLaw to learn more about non-compete agreements in detail. Let's dive right in …. 1. Fired Without Cause Were you fired without cause? If you were fired without cause, you most likely have nothing to worry about. Courts in New York generally will not enforce a non-compete against you in this situation because it's so unfair. If your employer is not willing to employ you, then it cannot prevent you from working within your field. It's just that simple. Also, most firings are without cause. Cause only exists if you do something seriously wrong like commit a major crime, steal from your employer or do something intentionally harmful to the company. If you were not fired, then go to steps 2 & 3 below. 2. Company Trade Secrets New York courts will not enforce a non-compete agreement against an employee unless the company has a legitimate interest to protect. In almost every case, the only possible legitimate interests are trade secrets. Therefore, your non-compete agreement is probably unenforceable unless you have access to your employer's trade secrets. Most people do not have access to trade secrets. For example, at the Coca Cola company, their trade secrets are the formulas for coke and other drinks, and they are closely guarded secrets. If you do have access to trade secrets or confidential information, then go to step 4 below. 3. Unique Skillset Do you have unique or extraordinary skills? This step only covers doctors, famous singers, actors & athletes and nationally renowned experts. Very few people have to worry about this. Unless you are one of them, your non-compete will not be enforced. 4. Reasonable Geographic Scope Is the non-compete agreement reasonable in time and geographic scope? This step only applies if you answered yes to step 2 or 3 above. Generally, a non-compete will be deemed reasonable if the restriction is limited to a year or less but that can vary. An agreement is reasonable in geographic scope if it covers the company's service area or market. For example, if you are a doctor who works for a medical practice that serves Brooklyn, then the non-compete should only cover Brooklyn. Or if you work for Google, most of their products have global reach so a non-compete with Google could cover the globe. Summing it Up Those are the four steps. If you answered yes to the first step or no to steps two and three, then your non-compete is unenforceable. These rules only apply to New York cases because other states have different rules. If you need help with a non-compete agreement or want to learn more about New York Non- Compete Core Concepts, please contact us.
The "Choice of Law" in Non-Compete Disputes
Apr 1, 2020 | By Ottinger Employment Lawyers | Read Time: 2 minutes
The "choice of law" in a non-compete dispute can impact the outcome of the case. New York, Massachusetts, and California, for example, have highly developed laws that favor employee mobility. Other states might be more inclined to enforce a non-compete agreement according to its terms. Therefore the question of which law applies can be determinative. Employers often try to avoid the employee friend laws of states like California by inserting a "choice of law" provision in the agreement. This happened to Patrick Miles who served as Vice Chairman of the Board of NuVasive, Inc., a medical device company based in San Diego and incorporated in Delaware. Even though NuVasive was based in California, Mr. Miles's non-compete agreement provided that Delaware law would apply. Mr. Miles left NuVasive in October 2017 and joined a competitor. NuVasive sued Mr. Miles in Delaware and the question in the case, as eventually posed by the court, was whether the choice of law provision was included for the purpose of "importing [Delaware's] well-developed body of commercial law" into the agreement or "as an attempt to contract around a fundamental public policy" of California against restraints on trade in the form of non-compete and non-solicitation clauses in the employment contract. NuVasive, Inc. v. Miles (Del. Ch. Ct. August 26, 2019). The court noted that Delaware generally respects parties' choice of law provisions in contracts disputes. However, because Delaware follows the Restatement (Second) of Conflicts of Law, the existence of a Delaware choice of law clause does not portend the end of the story. Rather, Delaware will adopt and apply another jurisdiction's law when the following test is satisfied: The other jurisdiction's law would apply absent the contractual choice of Delaware law, Failure to apply the other jurisdiction's law would frustrate a fundamental policy of the other jurisdiction, and The other jurisdiction's interest materially outweighs Delaware's interest in the matter. The court concluded that California law would apply since it was the state with the "strongest contacts to the contract." The court further found, consistent with its prior decision in Ascension Insurance Holdings, LLC v. Underwood (Del. Ch. Jan. 28, 2015) and citing California Business and Professions Code section 16600, that non-compete provisions are fundamentally against California policy. The only exception – for a non-compete covenant in connection with the sale of a business – that California makes to its section 16600 prohibition against contracts in restraint of trade is also set forth in the statute. The court noted that since its Ascension decision, California had added, in 2016, a new section to its labor code that only served to strengthen its already strong statement of public policy against non-competes. This law provided that: An employer shall not require an employee who primarily resides and works in California, as a condition of employment, to agree to a provision that would do either of the following: (1) Require the employee to adjudicate outside of California a claim arising in California. (2) Deprive the employee of the substantive protection of California law with respect to a controversy arising in California. Under this section of the California Labor Code, any provision of a contract that violates the above provision is voidable by the employee unless the employee has legal representation during negotiation of the forum or choice of law clause. In Ascension, the Delaware court had held that "California's specific interest [in its public policy against restraints of trade] is materially greater than Delaware's general interest in the sanctity of a contract that has no relationship" to Delaware. Similarly, the NuVasive court held in favor of Miles, concluding, for the non-solicitation clauses as well as the non-compete covenants, that California's public policy was "sufficiently strong that it must not be 'diluted by judicial fiat,'" and, therefore, substantially outweighed Delaware's general interest in freedom of contract. The lesson here is that the choice of law provision in a non-compete agreement should be ignored in these situations. The law of the state with the greater interest typically should apply and that is the state where the executive works. If the executive works in New York, for example, then New York law should apply.
New York Non-Compete: The Legitimate Interests Test
Decided almost a half century ago, Reed, Roberts Assoc. v Strauman, 40 N.Y.2d 303 (N.Y. 1976), remains a pillar of New York case law when determining if a non-compete is enforceable. With this decision, New York State's highest court established a framework for determining whether a non-compete (or any other restrictive covenant) is "reasonable" and, therefore, enforceable. Background In this case, the employer, Reed, Roberts Associates, Inc. ("Reed Roberts" and, sometimes, "the company"), provided advice and guidance to employers with respect to their obligations under New York State unemployment laws. The company's expertise also extended to advising their clients in the areas of worker's compensation, disability benefits, and pension plans. By 1976, Reed Roberts boasted over 6,000 customers, 21 offices nationwide, and gross sales of almost $4 million. In 1962, Reed Roberts hired John Strauman. As part of his employment contract, Mr. Strauman agreed to two restrictive covenants: a non-solicitation covenant and a non-compete covenant. The non-solicitation covenant provided that Mr. Strauman would never solicit any of Reed Roberts' clients. The non-compete provided that Mr. Strauman would not, for a period of three years from the date of his termination of employment, engage in or have an interest in any business of the same type as Reed Roberts, provided such business was located within the City of New York or the counties of Nassau, Suffolk and Westchester. During his 11-year tenure with Reed Roberts, Mr. Strauman became a valuable employee and received three promotions, eventually rising to the position of senior vice-president in charge of operations. A key employee, Mr. Strauman was both responsible for formulating company policy and instrumental in devising most of the forms utilized by the company in rendering its services and in setting up its computer system. "Importantly, however, he was not responsible for sales or obtaining new customers." Reed, Roberts Assoc. v Strauman, 40 N.Y.2d 303 (N.Y. 1976) p. 306. In 1973, Mr. Strauman left Reed Roberts and started his own company, Curator Associates, in direct competition with his former employer. Curator Associates was located in the same municipality as Reed Roberts, a geographical area specifically covered by the non-compete covenant that Mr. Strauman had signed in 1962. Reed Roberts brought a lawsuit against John Strauman and Curator Associates alleging that Strauman had been soliciting their customers and requesting that the court enforce the non-compete and non-solicitation covenants. Specifically, Reed Roberts requested relief via a court-issued injunction prohibiting Mr. Strauman and Curator Associates from (a) engaging in the business of unemployment tax control within the New York City metropolitan area for a period of three years, and (b) soliciting any of Reed Roberts' customers permanently. Rules for Evaluating Restrictive Covenants Under New York State law, generally, restrictive covenants such as non-compete and non-solicitation provisions are enforceable only to the extent that they are reasonable. Whether or not a provision is determined to be "reasonable" differs based on context. In Reed, Roberts Assoc. v Strauman, the New York Court of Appeals outlined a framework for determining whether a restrictive covenant is "reasonable" (and therefore enforceable) under New York law. Reasonableness Framework for Restrictive Covenants In the employment context, restrictive covenants (such as non-competes) will only be considered reasonable and therefore enforceable to the extent that such provisions are: reasonable in time and geographic area; necessary to protect the employer's legitimate interests; not harmful to the general public; and not unreasonably burdensome to the employee. In addition to considering the above framework for determining reasonableness, New York courts are more inclined to find that a restrictive covenant is reasonable if the facts show that there has been a conspiracy or breach of trust by the employee that results in commercial piracy. When is a Non-Compete Necessary to Protect an Employer's "Legitimate Interests"? Focusing on the second prong of the reasonableness framework described above, the New York Court of Appeals set forth the following two-part test for determining whether a restrictive covenant (such as a non-compete) is necessary to protect an employer's legitimate interest. A restrictive covenant is necessary to protect an employer's legitimate interests and enforceable on such grounds only: to the extent necessary to prevent the disclosure or use of an employer's trade secrets or confidential customer information; or where an employee's services are unique or extraordinary. When is a Non-Compete Not "Unreasonably Burdensome" to the Employee? Focusing on the fourth prong of the reasonableness framework, the New York Court of Appeals shed some light on when a non-compete might be considered unreasonably burdensome to the employee. According to the court, a restrictive covenant is unreasonably burdensome to an employee when it restrains the employee's right to apply, to their best advantage, the skills and knowledge (including those techniques which are skillful variations of general processes known to the particular trade) acquired by the overall experience of any previous employment.Id.at p. 307. The Reed court also noted an exception for members of "the learned professions." The Court explained that a restrictive covenant might not be unreasonably burdensome to such an employee, provided that the restrictive covenant is reasonable and such employee's services are unique or extraordinary. Procedural History On the first issue, the trial court ruled against Reed Roberts, refusing to grant an injunction that would enforce the non-compete and prohibit Mr. Strauman and Curator Associates from engaging in its business. The trial court explained that an injunction was not appropriate because (a) there were no trade secrets involved and (b) Mr. Strauman's services were not so unique or extraordinary (even though he was considered a "key employee"), and therefore the non-compete agreement was not reasonable and was therefore not enforceable. On the second issue, the trial court ruled in favor of Reed Roberts, granting an injunction to permanently prohibit Mr. Strauman and Curator Associates from soliciting Reed Roberts' clients. The trial court reasoned that it would be unjust and unfair for Mr. Strauman to utilize his knowledge of Reed Roberts' internal operations to solicit its clients. Upon appeal, the New York State Appellate Division affirmed the trial court's decision on both issues. The decision was […]
Federal Ban on Non-compete Agreements—Is It Possible?
Non-compete agreements have the attention of congress. A bipartisan effort to regulate non-compete agreements on a federal level was introduced in the U.S. Senate in October 2019 by Senators Chris Murphy (D-Conn.) and Todd Young (R-Ind.). Senate Bill 2614, the Workforce Mobility Act of 2019, proposes a near federal ban of all employee non-compete agreements, with limited exceptions for certain business transactions. The bill would have sweeping implications, but does it have any chance of becoming law? Workforce Mobility Act Would Limit Noncompete Agreements The Workforce Mobility Act (WMA) defines a "non-compete" agreement as any agreement between "a person and an individual performing work for the person" that restricts the individual, after the termination of the working relationship, from doing the following: Working for another person for a period of time. Working in a specified geographic area. Working for another person similar to the individual's work for the company. The WMA generally prohibits the use of non-compete agreements, except in limited instances. The bill permits non-compete agreements in connection with the sale of a business, as part of the dissolution of a partnership (or buyout of a person's partnership interest), or as part of a severance agreement with senior executives as part of the sale of a business (but the agreement is limited to 12 months and the employee must receive 12 months' severance pay). The WMA does not expressly prohibit non-solicitation agreements or non-disclosure agreements. Still, the definition of a "noncompete agreement" leaves open the possibility that these agreements may also be restricted. The bill does not prohibit agreements that prevent employees from sharing trade secrets. The Federal Trade Commission and the Department of Labor would be responsible for enforcing the WMA. The bill does allow workers to file suits for violations of the WMA. How the WMA Impacts Employees Non-compete agreements limit employee mobility, stifle wage growth and innovation, and prevent true competition. An estimated 40 percent of American workers have been subject to a non-compete agreement at some point in their careers. Given the growing use of these agreements in today's workforce, even with employees in low-paying jobs, the harm imposed on the economy and workers has not gone unnoticed. A prohibition on non-compete agreements would force companies to find a new way to protect their company's legitimate interests without impeding a person's ability to change jobs and earn higher wages. Passage of the WMA would also provide a uniform standard, which would ease the current discrepancies between states. Does the Workforce Mobility Act Have a Chance? The WMA is not the first attempt by legislators to regulate the use of non-compete agreements. Similar federal efforts failed in 2018 and January 2019, and many states have proposed or enacted legislation to limit the use of non–compete agreements. While the WMA received praise from many, its future seems uncertain, and some critics argue that safeguards against employer abuse of non-compete agreements already exist in the court system and that the bill goes too far. A hearing was held in November 2019, but there has been no movement since that time. While passage of the bill may be unlikely, it has again brought the issue of abuse of non-competes to the forefront and may be a good step towards negotiating a compromise bill. The Ottinger Employment Attorneys have drafted, reviewed, and negotiated non-compete agreements for over 20 years. Non-compete agreements can ruin your future career prospects, so it is critical that you carefully review and consider the long-term implications of these agreements. If you are contemplating entering into a non-compete agreement or fighting enforcement of an agreement, contact us today. Click here for more about non-compete agreements in New York.
Study Finds that Non-Compete Agreements are Bad for Employees and the Economy
A recent report released by the Economic Policy Institute ("EPI") is arguing in favor of prohibiting noncompete agreements after concluding that the increasing use of noncompete agreements may be contributing to rising wage inequality, stagnant wages, and decreasing job mobility. Relying on data from a national survey of private-sector businesses, EPI found that almost half of responding establishments required at least some of their employees to sign noncompete agreements. Should noncompete agreements be prohibited? Do they stifle competition? EPI certainly makes a strong argument, showing just how dangerous noncompetes can be for workers and the entire American workforce. The Growing Use and Abuse of Non-Compete Agreements Noncompete agreements are commonly found in employment agreements or as free-standing agreements, prohibit an employee from working for a competing business or starting their own competing business within a prescribed timeframe and within a specified geographical area. While their use was formerly limited to executives and other highly paid employees, the use of noncompete agreements has spread into all industries and to all levels of employees, including minimum wage employees and those working entry-level jobs. As a result of employer overreach, some states have made significant efforts to eliminate or limit the enforceability of noncompete agreements. Labor Market Trends EPI began its report by highlighting two main trends in recent decades: (1) rising inequality and stagnant wages among all but highly paid employees; and (2) the decline in job mobility and other measures of labor market fluidity. While many factors influence these trends, evidence suggests that the increasing use of noncompete agreements may be part of the problem. In terms of wage growth, workers often change jobs for a pay increase; when noncompete agreements limit mobility and competition, wages remain unchanged. Since noncompetes prohibit a worker from starting their own business or taking another job, there is a decline in dynamism in the national labor market. In fact, EPI noted that enforceability of noncompetes reduces the formation of new firms by 12% and is associated with an 11% increase in the length of time a worker remains at their job. Indeed, noncompete agreements are inhibiting workers' individual growth and impeding competition between organizations. Key Findings about Non-Compete Agreements The EPI study made several notable findings that supported its conclusion and argument for the prohibition of noncompete agreements. Almost half of businesses use noncompete agreements. Specifically, 49.4% of establishments reported that at least some of their employees were required to sign noncompetes; 31.8% of organizations indicated that all employees were required to enter into noncompetes (regardless of wages or duties). Based on the available data, EPI was able to estimate that 27.8% to 46.5% of private-sector workers are subject to noncompete agreements. Based on the assumption that there are 129.3 million people in the private-sector workforce, that means between 36 million and 60 million private-sector workers are subject to noncompetes. Mid-sized organizations are more likely to have all employees sign noncompete agreements. Establishments with 50 to 100 employees are less likely to use noncompete agreements than organizations with 100 or more employees. However, while larger organizations (1000 or more employees) are more likely to have legal counsel and sophisticated HR policies, mid-sized organizations (100–499 employees) are more likely to require all employees to sign noncompetes than both smaller and larger organizations. In the 12 largest states, 40% of establishments have at least some employees sign noncompete agreements. The EPI study reviewed the use of noncompete agreements in the 12 largest states (including California and New York) and found that 40% of organizations in these states use noncompete agreements with at least some of their employees. Shockingly, 45.1% of California establishments subject some of their employees to noncompete agreements even though noncompete agreements are unenforceable in that state. Why would California employers do this? They are relying on the fact that workers rarely challenge these agreements in court. The EPI study notes that employees' fears of being sued and pressure from employers causes workers to stay in positions regardless of whether the noncompete agreement is enforceable. This lack of mobility leads to lower or stagnant wages, and it stifles creativity and the development of new companies, products, and ideas. Significant use of noncompete agreements in business services and wholesale trades. Seventy percent of business services and wholesale trade organizations use noncompete agreements. These agreements are used less in transportation, education, health services, and leisure and hospitality establishments. Noncompete agreements used more frequently at higher-wage workplaces. While noncompete agreements are used more with higher-wage workplaces than lower-wage workplaces, 29% of establishments where the average wage is less than $13.00 use noncompete agreements for all workers. Many opponents of noncompete agreements take issue with the use of noncompetes on lower wage earners arguing, in part, that organizations are not protecting legitimate business interests by limiting employment options for entry-level and lower-wage employees. Higher use of noncompete agreements with employees with higher education levels. Noncompete agreements are used more frequently with workers with higher education levels, especially in organizations where employees usually have a four-year college degree or higher. In addition, 45% of establishments where the typical education level is a college degree or higher used noncompete agreements for all employees. Lastly, in 27.1% of organizations where the typical employee has only a high school diploma, noncompetes are used for all workers. Employers requiring mandatory arbitration are more likely to use noncompete agreements. More than half (53.9%) of establishments have mandatory arbitration procedures. EPI concluded that employers using mandatory arbitration are more likely to use noncompete agreements. Advocating to Ban or Limit Non-Compete Agreements In 2019, the Workforce Mobility Act of 2019 [hyperlink to blog post on this Act] was introduced in the United States Senate, which would prohibit the use of noncompete agreements on a federal level; this bill is unlikely to pass. Regardless, many states have enacted their own legislation to address abuses of noncompete agreements, but this can be confusing and cumbersome for employers working in multiple states. In addition to legislation, the EPI suggested the Federal Trade Commission […]
Why Not Blue Pencil?
"Blue penciling" refers to the convention whereby a court may exercise its discretion to modify parts of a contract that violate public policy, and which are, therefore, void. In the employment context, the questions whether, when and how much blue-penciling is warranted come up most frequently when courts are asked to enforce restrictive covenants such as non-compete and nonsolicitation agreements. A decision last year in the Colorado Court of Appeals, 23 LTD v. Herman, illuminates why some courts have retreated from "blue penciling." 2019 Colo. App. 113, No. 18CA0950. Ms. Herman Solicits a Customer In the Colorado case, the company, 23 LTD, doing business as Bradsby Group, sued a former employee, Tracy Herman, for breach of non-compete and nonsolicitation sections of her employment agreement. Herman had been hired by Bradsby as a legal recruiter. She had signed an employment agreement stating that she would not become for "twelve (12) months from the date of termination of employment … an owner, partner, investor, or shareholder in any entity that competes with Bradsby" within a restricted area. The restricted area was defined as any place within thirty miles of Bradsby's principal place of business, which was located in downtown Denver. The agreement also included a nonsolicitation provision restricting Herman from contacting any person or entity who had had any contact with Bradsby during Herman's last twelve months of employment with them. At the conclusion of her employment with Bradsby, Herman formed her own company, obtaining and designating a mailing address for it at a location outside the restricted area. She later reached out to a former job applicant from her time at Bradsby to inquire whether anyone in the contact's network might be interested in a position she was recruiting to fill. The contact had been previously offered a position with a law firm client of Bradsby's but had turned it down. When Herman contacted him later, he asked whether that law firm job might still be open. Herman then communicated with the law firm. The contact was eventually hired by the law firm, and Herman collected a fee from the hiring firm. A One Dollar Verdict At trial, a jury decided that Herman had not violated the non-compete provisions of the agreement but that she had violated the nonsolicitation provision. The jury awarded damages to Bradsby of one dollar. However, the district court set aside that verdict because it found the nonsolicitation provision of the contract to be so broad as to be void and in violation of Colorado law. The district court also declined to "blue pencil" the nonsolicitation provision to make it enforceable. Upon appeal, Bradsby argued that the district court erred and/or abused its discretion in declining to blue-pencil the nonsolicitation provision. Bradsby argued that the severability clause in its agreement obligated the district court to blue-pencil the agreement to conform to Colorado law. Stating that "Colorado law provides little guidance as to when, and to what extent, trial courts may blue pencil unreasonable non-compete provisions," the court of appeals considered case law from other jurisdictions. In discussing its reasoning, the court of appeals pointed out that even though a contract may grant a court the authority to modify an overly broad non-compete agreement, doing so would essentially require the court to rewrite an unlawful contract. No Blue Penciling The court noted that other states' courts had rejected the proposition that parties to a contract may delegate the responsibility to the court to draft language for them. "We are firmly convinced that parties are not entitled to make an agreement, as these litigants have tried to do, that they will be bound by whatever contract the courts may make for them at some time in the future." Quoting Rector-Phillips-Morse, Inc. v. Vroman, 489 S.W.2d 1, 4 (Ark. 1973). The court further explained that it is not itself a party to the contract. The parties "have no power or authority to enlist the court as their agent." Thus, parties to a contract cannot "contractually obligate a court to blue pencil non-compete provisions that it determines to be unreasonable." "Fundamentally, it is the obligation of a party who has and wishes to protect, trade secrets to crafting contractual provisions that do so without violating the important public policies of [the] state. That responsibility does not fall on the shoulders of judges." Citing Rector-Phillips-Morse, Inc. v. Vroman, 489 S.W.2d at 4; Bayly, Martin & Fay, Inc. v. Pickard, 780 P.2d 1168, 1175 (Okla. 1989). Accordingly, the court of appeals held that "it is not the function of a court to write or rewrite contracts for parties to enable enforcement of a contract that, as written, violates the public policy of the state." While a court may elect to blue pencil "an otherwise offensive restrictive covenant," the trial court "has broad discretion whether and when to exercise that authority."
Non-Compete Trends Favor Executive Mobility
Jul 5, 2018 | By Ottinger Employment Lawyers | Read Time: 3 minutes
An encouraging new trend we have seen lately is more states enacting laws or enhancing existing laws that limit the enforceability of non-compete clauses. The specific laws that apply to non-compete clauses in employment contracts vary greatly from one state to another. While some of the basic law around this area is outlined in court opinions — or "case law" — there are also legislatively enacted laws that affect what is and isn't allowed in different states. This year, Utah, Idaho, and Colorado joined recent moves by California and Illinois to strengthen laws covering an employee's right to switch employers. Meanwhile, case law around non-compete clauses also continues to develop. Non-compete clauses can take many forms. Generally speaking, a non-compete clause is a provision that restricts an employee from directly competing with the employer while in the employment relationship, from accepting later employment with a competitor of the employer or from going into business against the employer after the employment relationship has ended. A non-compete provision may cover only a short period after employment, or it may last many years. Non-compete agreements may or may not include provisions against "poaching" one's colleagues (known as "non-solicitation" clauses). Geographically, they may be limited in scope to a particular neighborhood, town or city, or they may reach across an entire state or region. They may only encompass the employer's existing clientele, or they may broadly restrict employment by the employee within an entire industry. Indeed, where these lines are drawn in a particular non-compete clause can determine whether or not the clause is considered legal and enforceable or null and void. Employers are, of course, fond of non-compete clauses because they perceive them as protecting competitive advantages and trade secrets while supporting workforce stability. For employees, though, non-compete clauses can have drastic and lasting effects on their ability to earn a living. And, for society in general, the impacts of non-competition agreements can be significant. Since they restrict people's ability to switch jobs easily, taking their accumulated expertise and knowledge with them, they impact social and geographical mobility as well as wage and salary growth. It is conceivable that left entirely unfettered, they could hurt innovation across whole industries. Thus, like other restraints on free-trade and competition, there are limits to what various jurisdictions — and the courts — consider acceptable in a non-compete clause. Here are some recent developments: This spring, Utah enacted a new law to limit the reach of non-compete agreements in the broadcasting industry. This law adds more strength to a bill they enacted two years ago. The two-year-old law in Utah imposed, in general, a one-year post-employment time limit on non-compete agreements. With this new law, employers in the broadcasting industry may not impose non-compete agreements on employees making a salary of less than $47,476 annually. Nor may they enforce a non-compete provision against an employee who was not terminated for cause unless the employee breached their employment contract. Also this spring, Idaho moved to repeal a burdensome requirement it had enacted two years ago which required employees to prove that their change of employers did not irreparably harm their former employer. With Idaho's repeal of Idaho Code Section 44-2704(6), the burden is once again on the former employer to show a likelihood of irreparable harm before a court may issue an injunction against the employee's new employment. In Colorado, the legislature passed a law that allows physicians to continue treating patients with "rare disorders" even when that would otherwise constitute a violation of the physician's non-compete agreement. This serves to clarify Colorado's existing law which generally prohibited non-compete agreements except in certain specific cases, such as for protection of trade secrets. In addition to these statutory changes, we've also seen recent case law affecting non-compete agreements: In Wisconsin, non-compete clauses are governed by Wisconsin Statute 103.465. In Wisconsin, to be enforceable, the statute requires that a non-compete covenant must be "reasonably necessary for the protection of the employer," only cover a reasonable period, only cover a reasonable territory and not be an unreasonable restraint on employees. In January this year, the Wisconsin Supreme Court held, in Manitowoc v. Lanning, that this statute, which generally refers to "covenants not to compete," also applies to non-solicitation agreements that would prevent employees from soliciting, inducing or encouraging other employees to terminate employment with one employer to accept employment with a competitor. The court found that the statute applies to all such covenants that are restraints of trade, regardless of whether they specifically include the term "compete" in their label. Last but not least, the South Dakota Supreme court decided a case in March of 2018 entitled Farm Bureau Life Insurance v. Dolly. In that case, the court declined to enforce a non-compete clause. The clause would have prevented a former insurance salesman from selling insurance to any of Farm Bureau's former customers, even though the former customers had approached him and he had not actually reached out to the customers or otherwise solicited them for their business. The court held that "an agreement not to solicit — rather than not to sell to — an insurer's existing customers [was] the only reasonable interpretation of [South Dakota Codified Laws 53-9-12]." The court concluded by stating, "The general rule against contracts in restraint of a lawful profession, trade, or business is a legislative expression of public policy…."
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Tag Archives: be proud
Caveat Pre-Emptor (Or, Why It's Okay to Brag a Little)
So, like, I'm a writer, right? Or at least, I'm trying to be. I aspire. Along with the legions of others.
And once in a while, and I do mean a good while, somebody will ask me "how's it going?" Or, even more rarely, the subject will come up for the first time and they'll ask "what are you writing?"
And before I can even properly formulate my response, the caveats start flooding out of me like the air from a punctured tire. "Well, I haven't been making the kind of progress I'd like, but —", or "you know, I really haven't been working on it for very long, so —", or "I don't have the time to really focus on it, and —", or, you know, fill in the blank with whatever disclaimer is handy. I'm basically telling the person that whatever it is isn't really up to standards (mine or theirs or some imaginary person's? WHO KNOWS, I DON'T), and it's basically just me noodling around on the page like that lame guy who knows three chords but pulls his guitar out at the party anyway.
All of which, I should point out, is true. I mean, I'd like to be making more progress, but THIS STUFF IS HARD. I really haven't been working on it very long — writing in general for maybe three years, this project in particular about a year, all told — but that's because THIS STUFF IS HARD and I only recently decided to take it on. And I don't have the time to really focus on it, because THIS STUFF IS HARD and it takes a ton of freaking time and I have, you know, a job, bills, a family, etc, etc.
Damn, I even caught myself doing it when I was doing a little journaling the other morning. In a bit of personal writing, from MYSELF to MYSELF, meant for absolutely nobody else's eyes ever, I put an asterisk on a statement of accomplishment. (I'd been for a run in the morning, and thanks to a nagging injury, my pace wasn't exactly what I'd prefer, so I hemmed and hawed — again, AT MYSELF — about the fact that I got out there and ran my morning miles.)
Something — something deeply rooted and insidious like the fungus at the heart of an ancient elm — makes me shy away from "bragging". Somehow, to talk about a thing I've done seems too much like grandstanding, like a ploy for accolades, like fishing for compliments. No, it's even worse than that — I have this thing where I can't stop thinking and analyzing. And because I'm always analyzing (especially when it comes to my own efforts and the stuff I create), I know, deep down in my bones, that what I'm doing is a far cry short of the best stuff out there, that it probably won't appeal to the average person, and that therefore any horn-tooting about it would be very much amiss. Something about pride and falls and all that.
But you know what? It's exactly because THIS STUFF IS HARD that it's worth bragging about. Getting it done, regardless of the quality of it, is worth tooting my own horn, I think. I mean, just to put it in perspective: how many people out there didn't run a 5k with their dog (in the rain!) before the sun even cracked an eye to reach for the snooze alarm? Almost all of them. How many people didn't pen the last words of a draft and start the long, thankless process of editing their novel? Almost all of them. How many people didn't carve time out of their lunch hour to itemize the entire plot of their story on notecards strictly for the purpose of mapping it out and seeing it better on the re-write? Pretty much all of them.
Almost all of them might sound like an exaggeration, but it's really not. I'm reminded of a passage from Douglas Adams explaining that the population of the universe is essentially zero. How does that work, you ask? Owing to the staggering amount of empty space, the amount of space that has people in it compared as a ratio to the amount of space that doesn't gives a value so infinitesimal that for all practical purposes, it might as well be zero. By that rationale, sure, there are tons of writers and runners in the world, but they are outnumbered on a planetary scale by people who aren't writers or runners — so, basically, virtually nobody writes or runs. (This is a fun way to claim significance for just about anything.)
And why didn't almost every person out there do any of these things? BECAUSE THIS STUFF IS HARD. But I did it anyway. Regardless of the time it took to finish, or the quality of the product as I look back on it, or how I felt or didn't feel as I was doing it, I did these things.
To hell with layering it, like a damned wedding cake, with asterisks. To hell with putting disclaimers on it. That's a hot pile of horse puckey. I did these things, and they were worth doing. Doesn't matter if it could've been better; doing it was better than not doing it. Doesn't matter if it took a long time; it's done now. And if I don't show some pride in the things I'm doing, who the hell else is gonna do it for me?
To hear me tell it, basically everything I've done is only a half-measure. Sure, I wrote a few plays after college, but they were just those lame murder-mysteries you can see anywhere. And yeah, I wrote a full-length play that was a smash hit at my old high school, but it's really too long and there's all kinds of things wrong with it. Yup, I've finished a novel, but I'm not published yet. Or yeah, I run, but only about fifteen miles a week these days. Sure, I've run long-distance races — but only a half-marathon. (By the way, somebody seriously needs to get on re-branding the half-marathon — the title itself is a caveat. And get out of here with that Pikermi crap, you can't be serious in a run if people think a digitized cartoon rat goes dancing across the finish line.)
See how lousy that sounds? But strip the caveats out, and that turns into:
I run four days a week. And I've run over 13 miles at a stretch before.
I've written plays. (Plural.) Which were performed for audiences which paid money to watch them.
I've written a novel. (And am working on more.)
See how much better that sounds? That sounds like a guy who's got his life together. That sounds like a guy you'd buy a cup of coffee for, if you could, and maybe hear a little bit of what he has to say.
So here's a challenge for me and for you: cut out the caveats and the disclaimers. Stop knocking yourself down before you've even properly stood up. Accomplish whatever it is you're trying to accomplish and be proud of the accomplishment.
Stuff your caveats in a sack. Then set the sack on fire and shoot it out of a cannon.
Leave a comment	| tags: be proud, caveats, do the thing, don't be a jerk, don't sell yourself short, Douglas adams, imposter syndrome, toot your own horn, Writing	| posted in Ramble, Running, Writing

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Gang of Six Grows to a Gaggle of Eight
The original Gang of Six came together last year to hammer out a deal to solve the debt ceiling crisis but failed to reach an agreement in the end.
President Barack Obama and Mitt Romney will crisscross the country during the next month offering different visions for how to fix the country's fiscal mess.
But in Washington, the senators in the Gang of Six — plus two newbies — will have a secret retreat next week hosted by Senator Mark Warner (D-VA) to start cobbling together a plan to avoid the looming fiscal cliff.
For this round of talks, the bipartisan group has added Sens. Mike Johanns (R-NE) and Michael Bennet (D-CO), who has grown close to Obama as he tries to capture Colorado this election season.
Senate insiders confirmed the upcoming session, although the group will not disclose its location.
"This group continues to meet and work toward a bipartisan solution," Warner spokesman Kevin Hall said.
Source: John Bresnahan and Jake Sherman | Politico
Biden Administration Needs to Invest in Early-Stage Climate-Friendly Energy Tech
U.S. to Host World Data System's International Program Office
University Students Collaborate With Oak Ridge on Cleanup Tools


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April 20, 2021updated May 20, 2021
Pop Art: Lady Gaga and Dom Pérignon's Charity Collaboration
A sculpture is the jewel in the crown of a new project in aid of the popstar's charitable foundation.
By Emma Al-Mousawi
The new 'Queendom' collaboration sees Lady Gaga as the radiant, spectacular Queen / ©Nick Knight
Never afraid to push the boundaries, American music superstar Lady Gaga has paired with Dom Pérignon for a bold new artistic collaboration in aid of the singer's Born This Way Foundation.
Aptly named 'The Queendom', the French champagne house claims the striking new project is a celebration of creative freedom and the embodiments of "the shared universe of Dom Pérignon and Lady Gaga." And that universe certainly is an eye-catching one.
[See also: New Clase Azul Mezcal Guerrero Celebrates Mexican Heritage]
The artistic venture, which includes fantastical pink-hued portraits of Gaga clutching a bottle of Dom Pérignon Rosé Vintage 2005 as well as a film directed by British fashion photographer Nick Knight, centers around the first piece of art released by Gaga and the champagne house: a limited-edition sculpture.
Designed by the popstar together with Nicola Formichetti, fashion director at Haus of Gaga (the eponymous name for Lady Gaga's creative team), the sculpture enfolds a jeroboam of Dom Pérignon Rosé Vintage 2005 almost like a veil frozen in time. The imaginative design is said to mimic the flow and movement of a magnetic dress.
The front of the sculpture has been created to appear like the flow and movement of a magnetic dress / ©Dom Pérignon
The sculpture (from behind), enfolds a jeroboam of Dom Pérignon Rosé Vintage 2005 / ©Dom Pérignon
Gaga is said to have selected the rosé as inspiration for the artwork after researching Dom Pérignon's history and the radical boldness behind the famed champagne house's rosé vintages.
Four Seasons New Orleans Unveils Dinner With Impressionists
Paul Lindahl on Transforming Art with Technology
Gallery 181 Opens Marianne Boesky Gallery Pop-up
[See also: Perrier-Jouët Belle Epoque 2013 Vintage Revealed]
Only 110 pieces have been produced, each hand-painted and signed by Gaga herself. Much more than a simple artwork, all sales will benefit the Born This Way Foundation, the charity which the pop star created with her mother Cynthia Germanotta to support the mental health of young people and create a kinder and braver world.
As well as the visual elements of the new Queendom artistic collaboration, Gaga and Dom Pérignon are said to be releasing a range of limited-edition collector's champagne bottles later in the year, though little information has been published as of yet.
The Limited-Edition Sculpture by Lady Gaga for Dom Pérignon is available for approximately $48,000 inquire via the Dom Pérignon website.
domperignon.com
Emma Al-Mousawi


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Why you should care about changes to the Endangered Species Act—and what you can do to help the animals
MaceyLavoie_articlephoto-300x225.jpeg
Macey Lavoie Updated Aug 14, 2019 @ 12:32 pm
endangered species sea otter swimming
Credit: heatherwest, Getty Images
If like us, you grew up watching nature documentaries and the adventures of animal conservationists like Steve Irwin and Jeff Corwin on Saturday mornings, you know about the Endangered Species Act. But for everyone else, let's break down what it does and why everyone's talking about it right now.
Since the law was introduced in 1973, it has been a key piece in protecting endangered species and bringing them back from the brink of extinction. It uses regulations as a tool for protecting wildlife, fish, and even plant species. Some of its most popular success stories include manatees, which were downgraded from "endangered" to "threatened" in 2017; grizzly bears, which have made a huge recovery, according to Yellowstone National Park; and America's own national emblem, bald eagles, which many consider the greatest success story of all.
Each one is a hard-earned victory in a world that is being decimated by habitat loss, overrun by plastic, and living under the looming threat of climate change. But it looks like that is all about to change after the Trump administration recently unveiled its revisions to law.
The White House says that the changes will increase effectiveness and transparency, but science experts believe it will ultimately limit the Endangered Species Act's reach. Here's how.
One of the largest differences is that, for the first time, climate change will not be a factor when deciding protection status. This comes as little surprise considering the Trump administration has made its stance on climate change woefully clear, but it eliminates a crucial aspect toward understanding and assisting animals that are in danger.
Also for the first time, economic impact will play a role in determining whether to protect habitats or classify a species as endangered. Regulators will be allowed to "conduct economic assessments—for instance, estimating lost revenue from a prohibition on logging in a critical habitat," according to The New York Times. This could damage years of conservationist effort, since one of the Endangered Species Act's most powerful tools has been preserving habitats for endangered or threatened species, allowing them to recover.
Despite this harsh blow, states are already acting against the changes. Since the official statement about gutting the Act both Massachusetts and California have vowed to sue the administration.
There are plenty of ways you can help show your support for the environment and the countless species that call this planet home. If you don't know where to start, here are some ideas.
1Learn about the endangered wildlife in your area.
Elephants, tigers, snow leopards, rhinos—these popular animals are often what come to mind first when you think of endangered species. They are more well-known and exotic and often far away. But a mussel or insect is just as likely to be endangered or threatened, and it's equally important to the ecosystem.
There are plenty of plants and animals that are at risk in your own neighborhood. Look for a running list of endangered species on your state's governmental resource page. Just learning about the native plants and animals can help us be more mindful of how our everyday lives might impact them.
2Contact your local representatives.
Your government officials are elected to champion the needs of your community, and this includes environmental practices. So, take the time to contact them and make your opinions known. You can find contact information for your state representatives here and your state senators here.
When election time rolls around be mindful of the candidates' stances on the environment and whether they align with yours. You can also organize to start a phone bank or to start petitions in your area to send to your officials.
3Donate to causes protecting the endangered species.
If you can, even a small donation can help in the fight to protect endangered species. The Center for Biological Diversity and Earth Justice are looking for donations to help their legal fights against the Trump administration's changes. You can also support any of these organizations, among many, many others:
The World Wildlife Fund
The Jane Goodall Institute
Gorilla Doctors
Save Our Monarchs Foundation
Project AWARE
4Volunteer to protect your local wildlife.
Nature reservations, parks, beaches and other local, public places are often overlooked and in need of help with upkeep. This can be anything from picking up trash in the area, educating visitors about the wildlife, or supporting local projects rehabilitating projects. The Nature Conservancy has a good list of local volunteer opportunities by state.
5Grow native plants in your garden and avoid invasive species.
It only makes sense that native species depend on native food sources. So why not help support the population by planting what they'd find in their habitat? This can be anything from growing flowers that are known to attract local pollinators to providing shelter for native species. A lot of the time an exotic plant has a native alternative. Another bonus is that pollinators naturally help your garden and plants thrive.
The U.S. Forest Service has information on invasive plant species and pollinator-friendly practices.
It may seem overwhelming, but there are ways to help. It is important to remember that humans aren't above the ecosystem we live in. Taking care of the planet and the creatures that live on it are crucial in making sure the world is livable for years to come.


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Tag Archives: Vladimir Putin
Trump is right on Nord Stream 2
By David B. Rivkin Jr. and Miomir Zuzul
July 22, 2018, in the Wall Street Journal
President Trump was right to criticize Chancellor Angela Merkel's plan for a new pipeline carrying Russian natural gas to Germany. This project threatens European independence and the North Atlantic Treaty Organization, and it was opposed by the Obama administration and many Senate Democrats, although not much was done to stop the pipeline's construction. Numerous European countries have also been sharply critical of Mrs. Merkel's energy plans. Mr. Trump has correctly sought to diminish Moscow's European energy footprint, belying claims he is a stooge of Vladimir Putin.
In 2015 the European Commission cited Russia's politically motivated disruptions of energy exports as one of the main causes of Europe's energy insecurity. Moscow is the largest energy exporter to Europe; Gazprom alone supplied almost 40% of Europe's natural gas in 2017. According to World Bank data, Gazprom's European gas prices last year were more than double the U.S. domestic price. Russia has also repeatedly used its gas to blackmail Europe, cutting off the supply in 2006, 2009 and 2014, and causing severe shortages in Eastern Europe.
Germany has sought for years to maintain a special energy relationship with Moscow as a means of securing its own energy-supply predominance in Europe. Once the Nord Steam expansion is completed, it will account for 80% of Russian gas imported to Europe, making Germany the Continent's major gas-distribution hub.
The Nord Stream 2 project has received particularly strong support from the center-left Social Democratic Party, a key member of Mrs. Merkel's shaky governing coalition. Gerhard Schröder, a former SPD chancellor, has served as chairman of Nord Stream 2 AG, a Gazprom-owned consortium.
Berlin signed the original Nord Stream pipeline deal with Russia during Mr. Schröder's chancellorship in 2005. In 2017 the Russian government nominated Mr. Schröder to the board of Rosneft, the Russian oil giant. German media report that Mr. Schröder was paid some €250,000 annually at Gazprom, and is expected to be paid €300,000 to €425,000 at Rosneft. But Germans have largely shrugged at the spectacle of a former chancellor on Russia's payroll.
Many other European countries, however, have been critical of Germany's Russian-energy romance. Thirteen EU states vehemently oppose the Nord Stream expansion. They are concerned about the loss of transit-fee revenue from existing pipelines that run mostly through Ukraine and the security risk of Russia's growing dominance over Europe's gas market. They have demanded the European Commission transfer negotiating power over the pipeline from Germany to the EU.
The new pipeline would enhance Russia's blackmail capability by enabling Moscow to cut off gas supplies to Eastern Europe without subjecting Western Europe to the same treatment. Not surprisingly, Eastern European states have taken the lead in trying to develop alternatives. In 2016 Croatia and Poland led the formation of the Three Seas Initiative, or 3SI, which united 12 states from the Baltics to the Balkans.
At a 3SI summit in Warsaw in June 2017, Mr. Trump pledged that the U.S. would bolster exports of liquefied natural gas to Europe so the Continent "can never be held hostage to a single supplier." That statement was anchored in the administration's broader strategy of transforming the U.S. into a pre-eminent low-cost global energy supplier.
Russia's gas stranglehold is a source of vulnerability as well as power. Europe accounts for more than 80% of Gazprom's exports. Energy accounts for almost half of Russia's exports and 40% of its national budget. The implementation of a 3SI energy plan would drain Russia's pocketbook and frustrate its geopolitical ambitions.
Moscow has recognized the challenge and done its best to block efforts to diversify European energy supplies. Russian proxies have moved to delay or stop the 3SI project. According to the Croatian media, Gasfin, a Luxembourg company acting as Gazprom's cat's-paw in Europe, is supporting local environmentalists opposed to construction of a new LNG terminal on Croatia's Krk Island. Gasfin has even purchased land on the island so that it can hobble the project via legal challenges—while at the same time suggesting that Gazprom might support the Krk project if it receives only Russian gas. During Croatian President Kolinda Grabar-Kitarovic's visit to Russia last October, Mr. Putin publicly offered a partnership to gasify Croatia.
Mr. Trump's leadership on this issue has had tangible results. Poland has committed to buying LNG from the U.S. and has already completed a new LNG terminal. It will not renew a contract with Gazprom set to expire in 2022, ending a 74-year exclusive partnership. U.S. LNG imports to Europe rose 22% last year, and will likely keep growing.
Yet the fate of 3SI is uncertain. The Trump administration should ramp up its energy strategy in two ways. First, promote U.S. investment in all facets of 3SI projects. Second, nudge European countries to accept a long-term package of sanctions on Russian energy, patterned after Carter- and Reagan-era sanctions, including restrictions on technology transfers and financing of Russian gas production and exports. If the Europeans balk, the U.S. should impose such sanctions unilaterally.
An all-out U.S. effort to stop Nord Stream 2 would help restore credibility in the aftermath of the Helsinki summit. Over time, this strategy would reduce Moscow's European gas exports dramatically, freeing Europe from Moscow's blackmail. American energy exports to Europe would be reliable and fairly priced. More Americans would have jobs, trans-Atlantic ties would be stronger, and it would be a major blow to the Putin regime.
Mr. Rivkin, a constitutional litigator, served in the Reagan and George H.W. Bush administrations at the White House Counsel's Office and the Energy and Justice departments. Mr. Zuzul is a former Croatian foreign minister and ambassador to the U.S.
Source: https://www.wsj.com/articles/trump-is-right-on-nord-stream-2-1532289915
This entry was posted in International law, politics and tagged Angela Merkel, Croatia, david b rivkin jr, Donald Trump, Germany, Miomir Zuzul, Russia, Vladimir Putin, Wall Street Journal on July 22, 2018 by David Rivkin.
Congress Can Respond to Putin With More Sanctions
By PAULA J. DOBRIANSKY And DAVID B. RIVKIN JR., Oct. 4, 2015 6:11 p.m. ET
From Ukraine to Syria, the Obama administration has consistently misread Russian President Vladimir Putin 's objectives and the implications of cooperating with him. This has led to costly failures, but the administration is unlikely to change its approach. Congress need not sit idle too. By enacting new sanctions on Russia, U.S. lawmakers can send a strong signal to Moscow that its continued aggression against Ukraine and growing complicity in a genocidal war in Syria will come at a heavy price.
After Russia annexed Ukraine's Crimea in 2014, the Obama administration and many U.S. allies imposed sanctions on Russian businesses and individuals. But those measures clearly haven't been effective in discouraging Mr. Putin's quest to exert Russian power and influence.
In Ukraine, despite the supposed cease-fire effected by the Minsk Accords negotiated by Germany, France, Ukraine and Russia, Moscow-supported aggression continues in the contested east. Russian troops remain in the region, as an extensive Sept. 14 report from the Atlantic Council documents, and Reuters has reported that new Russian military bases are being built.
In Syria, Mr. Putin, under the guise of fighting Islamic State, supports the Bashar Assad regime, which has used barrel bombs and chemical weapons in slaughtering tens of thousands of civilians, mostly Sunni Muslims—making Russia complicit in, and legally accountable for, these actions. The Obama administration over the past week has hinted that it might cooperate with Russia's anti-ISIS campaign.
The danger of association with an aggressor like Mr. Putin, who is also working with Iraq and Iran, can be seen in Russian airstrikes over the past few days directed not at ISIS but at other opponents of the Assad regime. The Obama administration's initial seeming openness to working with Mr. Putin in Syria has already compromised the White House's ability to hold Moscow accountable on any front, including for its aggression in Ukraine.
Under the U.S. Constitution, the president has formidable authority for conducting foreign policy, but there are several steps—practical and symbolic—that Congress can take that would demonstrate a resolve toward Russia that hasn't been forthcoming from the Obama administration.
On the symbolic side, Congress can legislate a finding, based on ample evidence, that the Russian military has committed war crimes in Ukraine, and is aiding and abetting the Assad regime's genocide and Iran's terrorism-sponsoring activities. Using the congressional bully pulpit can help drive the public debate, especially during the 2016 presidential election campaign.
Congress can also enact new sanctions that will have an immediate and profound effect—starting with the Russian oil-refining industry.
Despite Mr. Putin's far-reaching strategic aspirations, Russia is punching well above its weight. The Russian economy continues to shrink, buffeted by falling oil prices and Western sanctions, and 2014 capital flight has exceeded $150 billion. Hundreds of Russian casualties in Ukraine are causing discontent, with Russian media reporting how Russian contract soldiers—in the part-volunteer, part-draftee military—are refusing to deploy to Ukraine or Syria. According to the Moscow-based independent polling organization Levada, fewer than 14% of Russians support military intervention in Syria.
Russia's greatest vulnerability may be its refineries. While Russia is one of the world's top energy producers, its refining facilities are antiquated, with low product quality, no spare capacity, and infrastructure in desperate need of significant investment. The refining infrastructure is so weak that Russia ran out of gasoline in 2011, precipitating shortages and substantial popular discontent. Russian media reported that the head of the majority-government-owned Rosneft oil company, Igor Sechin, sent Mr. Putin a letter on July 15 warning of a major shortfall in refined products by 2016-17 unless the refining sector gets emergency financial assistance.
Most of Russia's approximately 50 major refineries date to the Soviet period. According to a 2014 report prepared for Russia's parliament, the refiners also require a steady supply of Western, particularly American, equipment. Current U.S. sanctions apply only to new Russian oil and gas production projects. But an embargo—even if only a unilateral one by the U.S.—on exports of refinery pumps, compressors, control equipment and catalytic agents would cause widespread shortages of refined products, putting tremendous pressure on Russia's civilian economy and Moscow's ability to carry out military operations. The Putin regime would suffer major political damage.
President Obama might veto such refinery sanctions legislation because of its potentially drastic effect, but as Russia's behavior becomes ever more outrageous, he might not be able to summon Democratic support as readily as he did for the Iranian nuclear deal. In any case, Congress would do well to make U.S. policy toward Russia a matter for serious discussion during an election year—and to remind Mr. Putin that with the Obama administration's days dwindling, a significant course correction in U.S. foreign policy could be on the horizon.
Ms. Dobriansky is a former undersecretary of state for democracy and global affairs in the George W. Bush administration. Mr. Rivkin is a constitutional lawyer who served in the Justice Department under Presidents Reagan and George H.W. Bush.
Source: http://www.wsj.com/articles/congress-can-respond-to-putin-with-more-sanctions-1443996688
This entry was posted in Uncategorized and tagged Barack Obama, Congress, constitution, David B Rivkin, Russia, Syria, Vladimir Putin, Wall Street Journal on October 5, 2015 by David Rivkin.


text:
Q: Check Box Values to List Jquery Hi all I am struggling to achieve my my goal and I really need some help.
I have a list of single check boxes that I need to be able to get the values and be able to put them in to a list
So for example 3 check boxes on the screen there could be more, the user clicks on one one or all of the them, and I want to be able to output the following:

Checkbox1 Value

Checkbox2 Value

Checkbox13Value

I also need to be able to save the selected values to a hiiden field as well like this if possible:
Checkbox1 Value | Checkbox2 Value | Checkbox3 Value
There will be 2 sections on the page with where I will need this functionality so I assume I will be looking into the div tags that contain the check boxes.
I have found some code but I get it to do what I need
     function updateTextArea() {
     var allVals = [];
     $('#c_b :checked').each(function() {
       allVals.push($(this).val());
     });
     $('#EXCUR').val(allVals)
     $('#t').val(allVals)
  }
 $(function() {
   $('#c_b input').click(updateTextArea);
   updateTextArea();
 });

My HTML will be like this:

   <input type="checkbox" value="one_name">
   <input type="checkbox" value="one_name1">
   <input type="checkbox" value="one_name2">

   <input type="checkbox" value="one_name" checked>
   <input type="checkbox" value="one_name1">
   <input type="checkbox" value="one_name2">

 <textarea id="t"></textarea>
 <input type="hidden" id="EXCUR" />

Any help with this would be great, I just cant get it to work
Many thanks in advance
Jason

A: Here is a fiddle of what I think you're looking for but if you answer my comment above I'll be able to help you further.

A: You can use jQuery's map() to extract the values you want into an array and then join the items in the array however you want.
Something like this:
function updateTextArea() {

 var items = $.map($('#c_b :checked'),function(el, ix) {
    return 'Checkbox' + (ix+1) + ' ' + $(el).val();
 });
 if(items.length > 0) {
    $('#t').val('

' + items.join('

') + '

');
    $('#EXCUR').val(items.join(' | '))
 } else {
    $('#t').val('');
    $('#EXCUR').val('');
 }
}

$(function() {
  $('#c_b input').click(updateTextArea);
  updateTextArea();
});

Fiddle to demonstrate

A:     function updateTextArea(){
        var vals = []
        var str="
";
    //iterate over checked boxes
        $("input:checked").each(function(){
            var v = $(this).val()
            vals.push(v)
            str += "
" + v + "
"
        })
        str+="
"

        $("#EXCUR").val(vals.join("|"));
        $("#t").val(str);
    }
    $(function(){
//bind click to all checkboxes in the page
        $(":checkbox").click(updateTextArea);

    })

redpajama_set_name: RedPajamaStackExchange


text:
Posts tagged "Mick Thongraya"
It All Begins at the Sea – Talay Luang
It really does begin at the sea. His new name "Talay" derives from the sea, where Moya (Sammy Cowell) rescues him from the depths. His condition may have seen better days, as they surface for air, she could see the cuts and bruises, and the blood seeping from his facial wounds. Moya is an optimist, and a warm-hearted person, so she takes him to the shore of Nupda Island and her resort Plaifah, in order to save his life. Just a moment before, "Talay" (Mik Thongraya) was Natee (or Tee), a man who recently returned to Thailand after his father threatened to cut ties with him, it is all too late (in cutting ties) because Natee's father ends up dying from a car accident…
Tagged: ทะเลลวง, Mick Thongraya, Sammy Cowell, Talay Luang
PSA – The Reluctant Bride
After back to back recaps, I told myself to take a hiatus from lakorns. We've been handed piles of melos lately, it's time to unwind and allow the brain/blood pressure to relax a little. This explains my lack of updates. But what did they say about timing? Once upon a time, we've all been reeled into the lakorn fever that is Mick Thongraya. He was divine in Karn La Krung Neung, a lakorn that had an addicting pace and great onscreen chemistry. Though the ending went downhill, the lakorn for the most part got everybody hot and bothered. But YOU GUYS, Mick in Jaosao Jam Yom is a must watch. I had to do everyone a favor and throw in a PSA: watch The Reluctant…
Tagged: เจ้าสาวจำยอม, Fonthip, Jaosao Jam Yom, Mick Thongraya
Who's Team Are You On? 'Petch Tud Petch' Premiers!
Even before the first episode aired, I posed a question on what team you'd like to be on, Team Weir or Team Mik in Petch Tud Petch, way before you even knew what side is the right side, or even if there is such a thing as the right side, because you know, your heart wants what it wants. Well I am here to report to you the first look of this action-packed lakorn, where every minute is chalk full of fighting scenes, you'll wonder if both sides of the party would even survive before you could submit your vote.
Tagged: Kwan Usamanee, Mick Thongraya, Petch Tud Petch, Weir Sukullawat
Once Upon a Time in My Heart – Episode 12 Final
We're here at the finale whether we like it or not. Once Upon a Time in My Heart wraps up its gangster drama much in line with the action you'd expect, all out brawls that bring characters together. Some characters turn over a new leaf while other characters fall back in their old ways, but one question remains, can Show cut out two episodes and still make it a compelling finale? Let's find out.
Tagged: Karn La Kreung Neung Nai Hua Jai, Mick Thongraya, Once Upon a Time In My Heart, Pimmy Pimrapa
Once Upon a Time in My Heart – Episode 11
Didn't think you could be any more sad, did you? Nope, welcome aboard our sad, sad ride into Daniel and Fahsai's world where self-inflicted pain takes precedence. How can I help you cope with the angst? Shall I curse Daniel, give Fahsai a hug, or just allow you to curl in the corner and cry? I will say that the tone is excellent, it's a gravity pull into their pain, and they're hurting so much that you just want to cut that tension with a knife, glue that distance together, and make them whole again. Finale is next week, and it's going to be one long wait until the conclusion. My heart still feels like it's out of place, and desperately needs Show to…
*Thud* Yeah, that's the sound of my heart dropping on the floor. Can you really fight for a love that pushes you away? What if there's no standard misunderstanding – but real fear – and that no matter how much you try, the person you love thinks you're better off without him. We're at an angsty impasse, is what it is. Damn if you do and damn if you don't. If you're going to hell anyway, why not go down in flames? Take what you can get and run. Tomorrow is another day, let's deal with it then.
Once Upon a Time in My Heart – Episode 9
Daniel takes center stage in this episode, and he continues to make me swoon. I didn't think Show could get any better, but it did, and I'm just jumping for joy. This episode takes the romance, the intrigue and even the gangster plot to the next level. Because if we only have three more episodes left, every minute counts. Now I'm going to forget that I just said that, because just thinking that this crack show will end with three more episodes will only break my heart. *sobs.
Fahsai certainly earned her fanfare this episode, didn't she? I'm impressed and doubly rooting for her even more. I'm sorry if I've ever doubted you! I love me a good kickass heroine, but this one fights with words. The BEST kind of fight. This episode situates us back (and nicely I might add) to where we like to be and why I'm still in love with this show. Which makes me wonder if that's a good or bad thing. Wait, don't answer that. I feel like cinderella and trying to post a recap before the clock strikes midnight. Today is not my day. My computer crashed and of course right before I am ready to post a recap. SIGH. ~Fia
I literally do a jig when I see that an episode is available. This episode turns things back to the gangster plot, with double crossing and mind games paramount to survival. I don't mind it too much since the layers are pretty interesting. Everyone has a motive in this show, and we learn that things are not always what they seem. The characters are in for a shocker when they find out who is behind the conflict between Suer Khao and Mungkorn Thong, and the Chern's family massacre. It's actually a reprieve to focus on the action and suspense, since the romance story did a number on me. But that KISS though. Swoon.
Pardon me while I die a little inside. You might want to lock your hearts and throw away the keys. Recaps completed! Enjoy!. ~Fia


text:
Criminal Justice Schools
Schools in Maryland
Criminal Justice Schools in Maryland
Criminal Justice Schools in Rosedale, MD
Rosedale has a general population of 19,199 and an overall student population of 23,584. Approximately 23,584 of Rosedale's students are enrolled in schools that offer criminal justice programs.
Of the 1 criminal justice schools in Rosedale, the largest criminal justice school, by student population, is The Community College of Baltimore County. In 2010, The Community College of Baltimore County graduated approximately 151 students from its criminal justice program.
In 2010, 151 students graduated with a criminal justice certificate in Rosedale. If you decide to attend a criminal justice school in Rosedale, you can expect to pay an average yearly tuition of $2,736.
In addition to tuition costs, you should plan on spending an average of $1,200 for books and supplies each year, while enrolled in a criminal justice program in Rosedale.
Criminal Justice Salaries and Career Outlook in Rosedale
Many criminal justice graduates choose to work as criminal justice professionals after graduation. If you choose to follow that path and remain in Rosedale, your job prospects are good. There were 25,280 criminal justice professionals working in Maryland and 14,680 working in the greater Rosedale area in 2010. The number of criminal justice professionals in Rosedale is expected to increase by 14% by the year 2018. This projected change is faster than the projected nationwide trend for criminal justice professionals.
The average salary you can expect to earn as a criminal justice professional in Rosedale is $26,750 per year. This is higher than the state-wide average salary for criminal justice professionals.
Criminal Justice Degree in Rosedale
Associates Degree in Criminal Justice
Bachelors Degree in Criminal Justice
Criminal Justice Classes
Criminal Justice schools in Arnold, Maryland
Criminal Justice schools in Washington DC
Criminal Justice schools in Baltimore, Maryland
Criminal Justice schools in Lincoln University, Pennsylvania
Criminal Justice schools in North East, Maryland
Criminal Justice schools in Arlington, Virginia
Criminal Justice schools in Stevenson, Maryland
Criminal Justice schools in Towson, Maryland
Criminal Justice schools in Vienna, Virginia
Criminal Justice schools in Rockville, Maryland
Criminal Justice schools in Wye Mills, Maryland
Criminal Justice schools in York, Pennsylvania
Criminal Justice schools in Beltsville, Maryland
Criminal Justice schools in Upper Marlboro, Maryland
Criminal Justice schools in Westminster, Maryland
Criminal Justice schools in Frederick, Maryland
Criminal Justice schools in Willow Street, Pennsylvania
Criminal Justice schools in Columbia, Maryland
Criminal Justice schools in Hyattsville, Maryland
Criminal Justice schools in Millersville, Pennsylvania
Criminal Justice schools in McLean, Virginia
Paralegal Schools in Rosedale
Criminal Justice Schools in Rosedale, Maryland
Online Regent UniversityMore Info Online Liberty University OnlineMore Info
1The Community College of Baltimore County
7201 Rossville Blvd., Baltimore, Maryland 21237


It's been a good week for game developers. Unreal Engine 4 went free. Unity 5 came out, and a massive chunk of its once premium features went free.
And now: Valve has just announced Source 2, the next generation of their Source game engine… and sure enough, it's "free to content developers".
Best known as the engine that powers games like Half-Life 2, Team Fortress, Counter-Strike: Go, Left 4 Dead, and Portal 2, the original Source engine* was primarily used for Valve's own titles. While a handful of third-party titles (Stanley Parable, Garry's Mod, Titanfall) are Source-powered, they've never really been Source's bread and butter.
Perhaps with this news, that'll change.
* built in 2004. Two thousand and friggin' four!
Now, a bit of a caveat: we don't know much about Source 2 yet. Hell, we don't even know the exact definition of "free".
So far, all Valve has said on the matter is that Source 2 will be "available for free to content developers".
Is that 100% free, or will they charge royalties a la Unreal (who charges 5% on every dollar after $3,000)? What, exactly, is a "content developer" — just indie developers, or are they giving it away to any and all?
It's something of a golden age of video game engine licensing. Not too long ago — hell, 5 years ago, licensing a big, brand name engine (including Source) involved gnarly negotiations, NDAs, and a small mountain of cash. Then Unity came along and changed the game.
Now you just find the engine with the most agreeable terms and start cracking away.


Editor's note: Research shows that whether or not a student is satisfied with training has no bearing on the impact of that training. Conclusion: happy sheets have no value.
Do #happy sheets work? Ask Traci Sitzman who has done the research. Her work on meta-studies, on 68,245 trainees over 354 research reports, attempt to answer two questions . . .


Title: Men's Pride! Luffy vs. Fujitora, Head-to-Head!
Episode Summary from one piece wikia : Law finishes talking with Sengoku, who refuses to discuss the D. in the former's name and says that the best way to honor Donquixote Rosinante's memory is to keep living. At the eastern port, Fujitora lifts all the rubble on Dressrosa high into the air, intending to drop it on the pirates and gladiators. Suddenly, Luffy arrives and attacks Fujitora, not intending to run away from admirals anymore. As they battle, however, Luffy calls out what his next attack will be before performing it. Eventually, Fujitora overpowers Luffy and sends him crashing into Dressrosa's coastline.
This Episode is licensed and distribute by Funimation and Crunchyroll. you may visit the website here Law finishes talking with Sengoku, who refuses to discuss the D. in the former's name and says that the best way to honor Donquixote Rosinante's memory is to keep living. At the eastern port, Fujitora lifts all the rubble on Dressrosa high into the air, intending to drop it on... more..